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Foreign Relations Compliance Department of Justice (DOJ)

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Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more

The Volkov Law Group

Forecasting the 2nd Trump Administration: Translating Initiatives to Enforcement and Compliance Priorities (Part I of III)

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As the dust settles on the U.S. Election, companies are quickly analyzing the impact for businesses, federal civil and criminal enforcement priorities and the implications for ethics and compliance. When a new Administration...more

The Volkov Law Group

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

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Sorry to start a four-part series with a reference to music from our long-ago past.  The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks?  Well,...more

Thomas Fox - Compliance Evangelist

Congress Fills a Corruption Hole: The Foreign Extortion Prevention Act (FEPA)

The compliance community has long recognized the gaping hole in the Foreign Corrupt Practices Act (FCPA). As a supply side law, it criminalizes the payment of bribes, not the demand to pay a bribe or extortion. The gap was...more

The Volkov Law Group

DOJ Resolves First Corporate Sanctions Case Involving Iran Sanctions Program

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The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message – companies are going to...more

The Volkov Law Group

Justice, Commerce and Treasury Departments Issue Comprehensive Tri-Party Voluntary Disclosure Guidelines for Sanctions and Export...

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In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated criminal and civil prosecutions for sanctions and export control violations.  The last piece in...more

The Volkov Law Group

SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV)

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In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more

Society of Corporate Compliance and Ethics...

US charges blockchain specialist; China designates US nonprofits

CEP Magazine (February 2020)  - Virgil Griffith, an American citizen, was arrested Nov. 30 after speaking on blockchain solutions at the April 2019 Pyongyang Blockchain and Cryptocurrency Conference in North Korea....more

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